https://www.taxtmi.com/caselaws?id=796384 Arm's length remuneration to a dependent agent permanent establishment exhausts further profit attribution where it fully reflects the agent's functions, assets and risks. The notes state that the enhancement rested exclusively on a revision order that had been quashed, while the agent's cost-plus remuneration was accepted as arm's length without any transfer-pricing adjustment or finding of inadequate pricing. Further attribution is permissible only if the arm's length analysis is deficient. The profit voluntarily offered under the dual taxpayer approach remained chargeable, and no additional profit attribution beyond the accepted remuneration was sustainable. en-us Mon, 04 May 2026 00:00:00 +0530 Wed, 05 Aug 2026 08:48:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796384 Arm's length remuneration to a dependent agent permanent establishment exhausts further profit attribution where it fully reflects the agent's functions, assets and risks. The notes state that the enhancement rested exclusively on a revision order that had been quashed, while the agent's cost-plus remuneration was accepted as arm's length without any transfer-pricing adjustment or finding of inadequate pricing. Further attribution is permissible only if the arm's length analysis is deficient. The profit voluntarily offered under the dual taxpayer approach remained chargeable, and no additional profit attribution beyond the accepted remuneration was sustainable. Case-Laws Income Tax Mon, 04 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796384